As a second step, the MNE group should identify and remove from the pool those costs that are attributable to services performed by one group member solely on behalf of one other group member. In creating a pool of payroll costs, for example, if group company A provides payroll services solely to group company B the relevant costs should be separately identified and omitted from the pool. However, if group company A performs payroll services for itself as well as for company B, the relevant costs should remain within the pool.
Chapter VII paragraph 7.57
Category: Chapter VII: Special Considerations for Intra-Group Services, D. Low value-adding intra-group services, OECD Transfer Pricing Guidelines (2017) | Tag: Application of the simplified approach, Intra-group services, Low value-adding services (LVAS), Pool of cost, Service fee, Services« Prev | Next »